Privacy policy | PRONEXUS Inc.

We handle personal information given to us by our clients in an appropriate manner, based on our Privacy policy.
Our Privacy policy and our purposes for using personal information are described below.

PRONEXUS Inc. Privacy policy

PRONEXUS provides support to clients for their corporate disclosures and investor relations. The protection of personal information is a fundamental aspect of our business, and we bear a heavy social responsibility in this regard. To ensure that we handle personal information in an appropriate manner, we have set up a personal information protection and management system as described below.

In each department where personal information is handled, we appoint an administrator to manage that data, to ensure compliance with the relevant standards, laws and regulations concerning personal information. We protect personal information by ensuring that these administrators do their jobs properly.
We take specific measures to ensure that personal information is acquired, used and passed on in a fair and lawful manner, and that it is not used in any way other than for its intended purpose.
We manage personal information securely and precisely, and have taken measures to prevent the unauthorized access, loss, destruction, falsification and leakage of personal information. In the unlikely event that any of these occur, we will immediately take corrective action.
We do not supply personal information to any 3rd party without the permission of the person to whom the information pertains. When we outsource the processing of personal information, the processor is contractually obligated to appropriately manage the information in the same way that we do.
The following contact office will quickly respond to any complaints or queries that you may have about personal information and the management systems that we use to protect it.
We continuously revise our personal information protection and management system in order to improve it.

March 8, 2005 established
September 1, 2009 revised
June 7, 2010 revised

President and Representative Director of PRONEXUS Inc. Takeshi Ueno

For enquiries about our handling of personal information, please contact our President's Office.
Tel:03-5777-3145
E-mail: asp@pronexus.co.jp

PRONEXUS Inc. About the handling of personal information

1. The name of the business handling the data and the administrator in charge of protecting personal information

PRONEXUS Inc.
Masahiro Tsukamoto, head of Compliance and Quality Management Division, Manager of Personal Information Protection

2. Purpose of use of personal information

If personal information is to be acquired directly in writing, then the intended use for this information must clearly be stated in advance. The uses for personal information acquired by any method other than directly in writing (for example, by telephone) or acquired indirectly from published data (such as a telephone directory, name register or website) are as follows.

(1) Information entrusted to us
- Use is limited to the purpose instructed to us by the party who entrusted us with the information.
(2) Information obtained from published data (including securities reports, official gazettes, websites, and commercially available name lists)
- Data for sale in the form of a PRONEXUS product or service, such as a corporate information database
- For supply as PRONEXUS data or data supplied through a PRONEXUS product or service
(3) Employee information acquired from companies in the PRONEXUS Group
- For use as business contacts within the Group companies
(4) Information acquired directly from the person themselves (but not in writing), such through face-to-face conversation or by telephone, etc.
- For supply as PRONEXUS data or data supplied through a PRONEXUS product or service

3. Disclosure of personal information to 3rd parties

PRONEXUS has corporate information databases that contain personal information. These databases are used to supply information to 3rd parties.

(1) Items of personal information supplied to 3rd parties
- 1. Personal information contained in disclosure documents submitted to stock exchanges (including stock exchanges overseas) or submitted as legally required.
  - Business contact name: official title, name
  - Representative director name: official title, name
  - Individual shareholders: name, number of shares owned
  - Corporate executive officers: official title, name, date of birth, CV highlights, number of shares owned
  - Corporate auditors: auditing firm name, auditing corporation name, auditor name
- 2. Personal information on a commercially available name list
  - Official titles and names listed in registries, including those of representatives
(2) Means or methods of supply of personal information to 3rd parties
The information may be sent via the Internet or by e-mail, etc.
(3) If the person to whom the information pertains demands that the personal information in (1) above not be supplied, we will not supply it to a 3rd party. Please contact us via the following help desks. Any personal information other than that listed above will only be supplied to a 3rd party with the prior consent of the person to whom the information pertains.

Moreover, prior consent from the party concerned will be obtained whenever providing personal information other than those listed above to a third party.

4. Outsourcing of tasks

We may outsource a portion of our work to help us achieve our objectives. We sign agreements with the contractors to whom we outsource this personal information, to guarantee that they manage it with the same level of care that we do.

5. Appropriate handling of personal numbers and specific personal information

PRONEXUS has set forth the following requirements to ensure the appropriate handling of personal numbers and specific personal information.

(1) Compliance with the relevant laws, regulations and guidelines, etc.
Comply with the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures, the Act on the Protection of Personal Information, and the Guidelines for Proper Handling of Specific Personal Information (for administrative organs, local governments, etc.) to ensure the appropriate handling of specific personal information, etc.
(2) Matters related to security control measures
Measures to ensure the secure management of specific personal information are set forth separately in our Specific Personal Information Handling Rules.

6. Contact office for complaints or requests concerning disclosure

The following contact office will properly respond to requests and complaints.

Contact office

Shiodome Building 5F, Kaigan 1-chome 2-20, Minato-ku, Tokyo 105-0022
General Manager, President's Office, Personal Information Protection Contact Office, PRONEXUS Inc.
Tel: 03-5777-3145 / E-mail: asp@pronexus.co.jp

Examples of requests

Notification of purpose of use of personal information subject to disclosure
Disclosure of personal information subject to disclosure
Amendment, addition or deletion of personal information subject to disclosure
Termination of use or provision of personal information subject to disclosure
Other complaints or matters to be discussed, etc.

Please understand that you may not visit our offices directly. Please read the following Procedures for the Disclosure of Personal Information and details of how to apply for information disclosure. PRONEXUS uses the following authorized personal information protection organization to handle this work. If you have any complaints about our handling of personal information, you may contact the organization.

Name of authorized personal information protection organization

Japan Information Processing and DEvelopment Center ("JIPDEC")

Who to contact for resolution of complaints

Personal Information Protection Consultation Service Office Roppongi First Building 12F, Roppongi 1-chome 9-9, Minato-ku, Tokyo 106-0032
Tel: 03-5860-7565 or 0120-700-779

7. Discretion to supply information

PRONEXUS uses personal information for the purposes listed in "2. Purpose of use of personal information" above. The supply of personal information is discretionary; however, if you do not agree to supply personal information, we may not fulfill some or all of the purposes of use listed above.

PRONEXUS Inc. Procedures for the Disclosure of Personal Information

At PRONEXUS, we will respond to any request regarding the personal data that we possess, whether the request is from the person to whom the information pertains or from an agent representing that person. These may include requests for notification of the purpose of use, corrections to the details, addition or deletion of information, termination of use or termination of supply to a 3rd party (hereafter "alternations, etc.") as well as requests for disclosure.

Ⅰ Procedure for a request for the disclosure of personal information

1．Who to apply to

To request the disclosure, please contact our Personal Information Protection Contact Office (refer to the section on our handling of personal information) by telephone, etc., and ask for a "Disclosure of personal information request form." The form that you need to fill in and submit will be sent to you.

2．Documentation to be submitted and who to submit it to

(1) A fully completed request form that we have sent to you
(2) A copy of your Japanese health insurance card or other official document that will verify your name and address. (If you going to send in a copy of your family register or other document that may contain sensitive information, we ask that you ink/paint out the sensitive portions first. We will appropriately handle the documents you send to us, and will treat them as personal information.)
(3) Place a total of at least 2,000 yen-worth of postage stamps as a request fee (see 4. below) into the envelope containing your documents, and post it to our Personal Information Protection Contact Office. On the front of the envelope, please write "Request form enclosed" in red.

3．Request by an agent

If the person making the request is a legal representative of a minor or adult ward, or an agent entrusted by the person to whom the information pertains to request disclosure of that information on their behalf, then either of the following documents (1) or (2) must also be included in the envelope together with the documents listed in the previous paragraph.

(1) If a legal representative
- Documentation confirming legal agency
  One (1) (Family register. If the legal representative has parental authority, then a copy of a health insurance card that lists the dependents of the parent) is acceptable
- Documentation to confirm that the applicant is the legal representative of the minor or adult ward
  One (1) (copy of the legal representative's driver's license or passport or other such official document)
(2) If an agent entrusted to make the request
- One (1) power of attorney
- One (1) registration certificate of the seal of the person to whom the information pertains

4．Fees and their collection

A fee of 2,000 yen shall be charged each time a request for disclosure of the personal information that we hold is made. Please include 2,000 yen-worth of postage stamps in the envelope along with your request documents. If the fee payment is insufficient or is not sent, we will notify you. If you do not pay the fee within the required period, we will assume that you have not made a request.

* In instances where "personal data we hold" is not disclosed
We will not make the requested disclosure in the event of any of the following. If we decide not to disclose the information, we will inform you of the reason. Even if we decide not to disclose the information, we will not refund your disclosure fee.
- We are unable to confirm the person to whom the information pertains (for example, there is inconsistency between the address listed in the request form, the address listed in the documents used to confirm the person to whom the information pertains, and the address listed in the personal information of that individual that we have in our records)
- We are unable to confirm the legal agency of the request by the agent
- The request documentation is incomplete or has not been properly correctly
- The request does not call for the disclosure of "personal data we hold"
- There are concerns that the disclosure will endanger the life or injure the physical being of, or damage assets of or cause other harm to the rights or interests of the person to whom the information pertains or to a 3rd party.
- There are concerns that the disclosure will pose a significant hindrance to the proper conduct of our business.
- The disclosure will violate laws and regulations.

Ⅱ Procedures for the alteration, etc. of personal information

1．Who to apply to

For alternations, etc. to personal information (requests for notification of the purpose of use, corrections to the details, addition or deletion of information, termination of use, deletion or termination of supply to a 3rd party) please contact our Personal Information Protection Contact Office by telephone, etc. and request a Personal Information Changes and Usage Stoppage Request Form. Alternatively, you may make your request directly to our client manager.

2．Documentation to be submitted and who to submit it to

After filling out all parts of the request form that we have sent to you, place the following documents in an envelope and post it to our Personal Information Protection Contact Office. (The documents that you send to us will be appropriately treated as personal information.)

A copy of your Japanese health insurance card or other official document that will verify your name and address. (If you are to send in a copy of your family register or other document that may contain sensitive information, we ask that you ink/paint out the sensitive portions first. If you make your request to our client manager, and we are able to confirm that you are the person to whom the information pertains, the client manager will take care of the necessary procedures on your behalf.

If a request is made to your account manager, once the identity of the client is verified, your account manager will proceed to complete the required procedures.

3．Request by an agent

The procedure for a request for disclosure is the same as in 3.

4．Fees and their collection

No fee will be charged for the alternation, etc. of information.